Thomas W. and Pamela A. Hill - Page 8

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          attributable to activities not engaged in for profit.  Section              
          183(b)(1), however, provides that deductions that are allowable             
          without regard to whether the activity is engaged in for profit             
          shall be allowed.  Section 183(b)(2) further provides that                  
          deductions that would be allowable only if the activity were                
          engaged in for profit shall be allowed, “but only to the extent             
          that the gross income derived from such activity for the taxable            
          year exceeds the deductions allowable by reason of” section                 
          183(b)(1).  Accordingly, $892 of the expenses incurred in                   
          petitioner’s fishing activity should have been allowed as an                
          offset to the $892 of income received from the activity.                    
               Section 183(c) defines an “activity not engaged in for                 
          profit” as any activity other than one for which deductions are             
          allowable under section 162 or under paragraph (1) or (2) of                
          section 212 for the taxable year.  The standard for determining             
          whether the expenses of an activity are deductible under either             
          section 162 or section 212(1) or (2) is whether the taxpayer                
          engaged in the activity with the “actual and honest objective of            
          making a profit”.  Ronnen v. Commissioner, 90 T.C. 74, 91 (1988);           
          Dreicer v. Commissioner, 78 T.C. 642, 645 (1982), affd. without             
          opinion 702 F.2d 1205 (D.C. Cir. 1983).  While a reasonable                 
          expectation of profit is not required, the taxpayer’s profit                
          objective must be bona fide.  Hulter v. Commissioner, 91 T.C. 371           
          (1988); sec. 1.183-2(a), Income Tax Regs.  Whether a taxpayer had           






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